Two Racial Slurs Not Enough for Hostile Work Environment

February 9th, 2012 by JBWK

In a decision granting summary judgment to Fairfax County Public Schools, a federal judge in Alexandria ruled that two alleged instances of a coworker using racial slurs was insufficient to create a hostile work environment.

The plaintiff claimed a coworker twice used racial epithets toward her, creating a hostile work environment based on her race. However, the trial court ruled that, even if the facts were true, the alleged conduct was not enough to create a hostile work environment.

After taking into account the frequency, severity, and quantity of alleged uses of racial slurs, the judge held that two instances weren’t enough and dismissed the case after finding the limited use is insufficient to alter the conditions of the plaintiff’s employment or create an abusive working environment.

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